© Sara M. Taylor 2002 Document Production and Organization for Litigation Paralegals in California

© Sara M. Taylor 2002 Audience Background Number of years as paralegal Number of years as paralegal Type of law Type of law Federal/State Court Federal/State Court

© Sara M. Taylor 2002 Audience Background Size of Firm Size of Firm IT Department IT Department Technical Ability Technical Ability

© Sara M. Taylor 2002 Acquisition and Analysis of Documents Acquisition and Analysis of Documents

© Sara M. Taylor 2002 Understanding of the Case Attorney Input Attorney Input Examination of the Complaint Examination of the Complaint Analysis of Evidence Needed Analysis of Evidence Needed Review of Documents Review of Documents Timeline or Chronology Timeline or Chronology

© Sara M. Taylor 2002 Attorney Input Facts Facts Issues Issues Decision Makers Decision Makers Dates Dates

© Sara M. Taylor 2002 Examination of Complaint Parties Parties Causes of Action Causes of Action Allegations Allegations

© Sara M. Taylor 2002 Analysis of Evidence Needed Breach of Contract Breach of Contract Existence of Contract Existence of Contract Terms/Conditions Terms/Conditions Breach Breach Damages Damages Negligence Duty of Care Breach of Duty Causation Damages

© Sara M. Taylor 2002 Document Review Look for Relationships Look for Relationships Correspondence Correspondence Meetings – Boards, decision makers, parties Meetings – Boards, decision makers, parties Memos Memos s s Files Files Diaries/Calendars/Journal Diaries/Calendars/Journal

© Sara M. Taylor 2002 Chronology General with all information General with all information Specific Time Frames Specific Time Frames Key Dates Key Dates

© Sara M. Taylor 2002 General 10/05/00 Contract signed by parties 11/20/01 Production problems 01/03/02 Manufacturer fails to deliver 02/04/02 Customer complaints 03/05/02 Parties meet to discuss 11/18/03 Plaintiff files suit

© Sara M. Taylor 2002 Sources of Documents Client Client Other Parties to Litigation Other Parties to Litigation Third Parties Third Parties Public Records Public Records

© Sara M. Taylor 2002 Client Files Files Memos Memos Correspondence Correspondence s s Diaries/Journals Diaries/Journals Telephone records Telephone records Calendars Calendars Other parties Other parties Authorization (59) Authorization (59)

© Sara M. Taylor 2002 Other Parties to Litigation Focus on assembling, organizing and narrowing the documents that will form the primary body of evidence of the case, the names of individuals that will be potential witnesses, and the central dates and facts related to the key events Focus on assembling, organizing and narrowing the documents that will form the primary body of evidence of the case, the names of individuals that will be potential witnesses, and the central dates and facts related to the key events

© Sara M. Taylor 2002 Other Parties to the Litigation Interrogatories (61) Interrogatories (61) Depositions (68) Depositions (68) Requests for Admission Requests for Admission Mental/Physical Exams Mental/Physical Exams Expert Witness Discovery Expert Witness Discovery Document Requests (65) Document Requests (65)

© Sara M. Taylor 2002 Document Requests Propounding Party Propounding Party Causes of Action Causes of Action Evidence Evidence Damages Damages Proof Evidence Proof Evidence Responding Party Course of Business Responsive to Request Objections Privilege Privacy Attorney Client Doctor/Patient Work Product Doctrine All Inclusive Documents

© Sara M. Taylor 2002 Motion to Compel Time Considerations Time Considerations Notice Notice Separate Statement Separate Statement Declaration Declaration

© Sara M. Taylor 2002 Third Party - Subpoenas Deposition Subpoenas Deposition Subpoenas Personal Appearance and Production of Documents and Things (71) Personal Appearance and Production of Documents and Things (71) Production of Business Records (72) Production of Business Records (72) Attorney Support Services Attorney Support Services

© Sara M. Taylor 2002 Public Records Morehelp.net Morehelp.net Websites Websites Secretary of State Secretary of State County Courts County Courts

© Sara M. Taylor 2002 Websites Trial courts in CA (143) Trial courts in CA (143) californiadiscovery.findlaw.com californiadiscovery.findlaw.com californiadiscovery.findlaw.com